1 About this Policy
1.1 This policy explains when and why we collect personal information about our members and instructors, how we use it and how we keep it secure and your rights in relation to it.
1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
2 Who are we?
3 What information we collect and why?
|Type of information||Purposes||Legal basis of processing|
|Member's name, address, telephone numbers, email addresses, voice/section whilst a current member and for up to a year after ceasing to be a member||Managing the Member's membership of the Choir||Performing the Choir's duties regarding the Member. For the purposes of our legitimate interests in operating the Choir|
|Photos and videos of Members||Putting on the Choir's website and social media pages||Consent. We will seek the Member's consent on their membership application form and each membership renewal form and the Member may withdraw consent at any time by contacting us by email.|
|Name, email address and telephone numbers of each Choir committee member||Information published on the Member Zone on the Choir website||For the purposes of our legitimate interests in operating and promoting the Choir|
|Name, address, email address and telephone number for non-members purchasing concert tickets or workshop admissions for up to a year after the date of the concert or workshop||Sale of tickets and workshops||For the purposes of our legitimate interests in operating the Choir|
The Choir does not hold credit card or bank details for members or non-members.
4 How we protect your personal data
4.1 We will not transfer your personal data outside the EU without your consent.
4.2 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
4.3 Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
4.4 For any payments which we take from you online we will use a recognised online secure payment system, such as PayPal.
4.5 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
5 Who else has access to the information you provide us?
5.1 We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where we are required to do so by law or as set out in the table above or in paragraph 5.2 below.
5.2 We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to print newsletters and send you mailings). We do this for the purpose of our legitimate interests in operating the Choir and for performing our agreement with you. However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes. It is possible that third parties may themselves engage others (sub-processors) to process your data. Where this is the case third parties will be required to have contractual arrangements with their sub-processor(s) that ensure your information is kept secure and not used for their own purposes.
6. How long do we keep your information?
6.1 We will hold your personal data on our systems for as long as you are a member of the Choir and for as long afterwards as it is in the Choir’s legitimate interest to do so or for as long as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.
6.2 We securely destroy all financial information once we have used it and no longer need it.
7. Your rights
7.1 You have rights under the GDPR:
7.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner:
0303 123 1113
Cheshire SK9 5AF
For more details, please address any questions, comments and requests regarding our data processing practices to our Data Protection Manager: firstname.lastname@example.org.